Page 1 Filing # 90602002 E-Filed 06/05/2019 11:15:17 AM
IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
CASE NO.: CACE-19-EDGAR MONSERRATT, as_ Personal
Representative of THE ESTATE OF
EDGAR MONSERRATT MARTINEZ,
Deceased,
Plaintiff,
V.
TESLA, INC. a/k/a TESLA FLORIDA,
INC., HALSTON LOYD, JAMES BB.
RILEY, individually, JAMES B. RILEY as
the Personal Representative of THE
ESTATE OF BARRETT RILEY, Deceased,
and JR CORPORATE SERVICES GROUP
LLC, a Florida limited liability company,
Defendants.
/
NOTICE OF PRODUCTION FROM NON-PARTY
YOU ARE HEREBY NOTIFIED that after ten (10) days from the date of service of this
Notice the undersigned will apply to the Clerk of this Court for the issuance of the attached
subpoenas directed to those listed below, who are not parties, to produce the items listed at the
time and place specified in their subpoenas:
1. NBC 6 South Florida
15000 SW 27' Street
Miramar FL
2. CBS 4 Miami
8900 SW 18" Terrace
Doral FL
[INTENTIONALLY LEFT BLANK]
** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/05/2019 11:15:17 AM.**#*Page 2 WE HEREBY CERTIFY that a true and correct copy of the foregoing has been served
via electronic mail and facsimile this 5“ day of June, 2019, to all parties on the attached list.
SCHLESINGER LAW OFFICES, P.A.
Attorneys for Plaintiffs
1212 SE Third Avenue
Fort Lauderdale, Florida
/s/ Zane Ber
Scott P. Schlesinger, Esq.
Florida Bar No.: scott@schlesingerlaw.com
Jonathan R. Gdanski, Esq.
Florida Bar No.: jonathan@schlesingerlaw.com
Zane Berg, Esq.
Florida Bar No.: zane(@schlesingerlaw.comPage 3 SERVICE LIST
SCOTT P. SCHLESINGER, ESQ. PHILIP HARNETT CORBOY, JR., ESQ.
JONATHAN R. GDANSKI, ESQ. CORBOY & DEMETRIO, P.C.
ZANE BERG, ESQ. 33 N. Dearborn Street
SCHLESINGER LAW OFFICES, P.A. Chicago IL
1212 Southeast Third Ave Tel: (312)346-
Fort Lauderdale FL 33316 fhe@corboydemetrio.com
Tel: (954)320-9507 Co-Counsel for Plaintiff
Fax: (954)320-
scott@schelsingerlaw.com
jonathan@schlesingerlaw.com
zane@schelsingerlaw.com
priscilla@schlesingerlaw.com
Attorneys for Plaintiff, Edgar Monserratt, as Personal Representative of The Estate
of Edgar Monserratt Martinez, Deceased
ROBERT J. RUDOCK, ESQ.
WHITNEY V. CRUZ, ESQ.
BOWMAN AND BROOKE LLP
Two Alhambra Plaza, Suite
Coral Gables, FL
Tel: (305) 995-
Fax: (305) 995-
Robert.Rudock@bowmanandbrooke.com
Whitney.Cruz@bowmanandbrooke.com
Attorneys for Defendant, Tesla, Inc. d/b/a Tesla Florida, Inc. and Halston Loyd
LAURIE A. PRIMUS, ESQ.
SELLARS, MARION & BACHI, P.A.
811 North Olive Avenue
West Palm Beach, FL
Telephone: (561) 655-
Facsimile: (561) 655-
Service email: pleadings@smb-law.com
Attorneys for Defendants, James B. Riley and JR Corporate Services Group, LLCPage 4 IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
CASE NO.: CACE-19-EDGAR MONSERRATT, as_ Personal
Representative of THE ESTATE OF
EDGAR MONSERRATT MARTINEZ,
Deceased,
Plaintiff,
V.
TESLA, INC. a/k/a TESLA FLORIDA,
INC., HALSTON LOYD, JAMES BB.
RILEY, individually, JAMES B. RILEY as
the Personal Representative of THE
ESTATE OF BARRETT RILEY, Deceased,
and JR CORPORATE SERVICES GROUP
LLC, a Florida limited liability company,
Defendants.
/
SUBPOENA DUCES TECUM (MAIL IN ONLY)
TO: NBC 6 South Florida
15000 SW 27 Street
Miramar FL
YOU ARE COMMANDED TO appear at the law offices of Schlesinger Law Offices,
P.A., 1212 SE Third Ave., Ft. Lauderdale, FL 33316 within TEN DAYS of the date of service
of this subpoena*, and to have with you the following documents and materials:
1. Full, unedited and complete copies of any and all photographs, video recordings,
and/or broadcast tapes related to the crash of a Tesla Motor vehicle (operated by Barrett
Riley) on Seabreeze Boulevard in Fort Lauderdale, FL on May 8, 2018, aired and/or
reported on May 8, 2018 and thereafter.
2. Full, unedited and complete copies of any and all photographs, video recordings,
and/or broadcast tapes depicting the scene of the crash of a Tesla Motor vehicle (operated
by Barrett Riley) on Seabreeze Boulevard in Fort Lauderdale, FL on May 8, 2018, aired
and/or reported on May 8, 2018 and thereafter.
3. Full, unedited and complete copies of any and all photographs, video recordings,
and/or broadcast tapes depicting the damages to the Tesla Motor vehicle (operated by
Barrett Riley) which crashed on Seabreeze Boulevard in Fort Lauderdale, FL on May 8,
2018, aired and/or reported on May 8, 2018 and thereafter.Page 5 4. Full, unedited and complete copies of any and all photographs, video recordings,
and/or broadcast tapes depicting the occupants of a Tesla Motor vehicle (operated by
Barrett Riley) which crashed on Seabreeze Boulevard in Fort Lauderdale, FL on May 8,
2018, aired and/or reported on May 8, 2018 and thereafter.
YOUR RESPONSE IS DUE BY:
10 DAYS FROM THE DATE OF SERVICE OF THIS SUBPOENA
*You may mail or deliver copies to the attorney whose name appears on this
subpoena and thereby eliminate your appearance at the time and place
specified above.
These items will be inspected and may be copies at that time. You will not be required to
surrender the original items. You may comply with this subpoena by providing legible copies of
the items to be produced to the attorney whose name appears on this subpoena on or before the
scheduled date of production. You may condition preparation of the copies upon the payment in
advance of the reasonable cost of preparation. You have the right to object to the production
pursuant to this subpoena at any time before the production by giving written notice to the attorney
whose name appears on this subpoena.
THIS WILL NOT BE A DEPOSITION, NO TESTIMONY WILL BE TAKEN.
If you fail to: (1) Appear as specified, or
(2) furnish the records instead of appearing as provided above, or
(3) object to this subpoena;
You may be in contempt of court. You are subpoenaed by the attorney whose name
appears on this subpoena and unless excused from this subpoena by the attorney or the Court,
you shall respond to this subpoena as directed.
DATED this day June, 2019.
SCHLESINGER LAW OFFICES, P.A.
Attorneys for Plaintiffs
1212 SE Third Avenue
Fort Lauderdale, Florida
/s/ Zane Ber
Scott P. Schlesinger, Esq.
Florida Bar No.: scott@schlesingerlaw.com
Jonathan R. Gdanski, Esq.
Florida Bar No.: jonathan@schlesingerlaw.com
Zane Berg, Esq.
Florida Bar No.: zane@schlesingerlaw.comPage 6 IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
CASE NO.: CACE-19-
EDGAR MONSERRATT, as_ Personal
Representative of THE ESTATE OF
EDGAR MONSERRATT MARTINEZ,
Deceased,
V.
Plaintiff,
TESLA, INC. a/k/a TESLA FLORIDA,
INC., HALSTON LOYD, JAMES BB.
RILEY, individually, JAMES B. RILEY as
the
Personal Representative of THE
ESTATE OF BARRETT RILEY, Deceased,
and JR CORPORATE SERVICES GROUP
LLC, a Florida limited liability company,
Defendants.
/
SUBPOENA DUCES TECUM (MAIL IN ONLY)
TO: CBS 4 Miami
8900 SW 18 Terrace
Doral FL
YOU ARE COMMANDED TO appear at the law offices of Schlesinger Law Offices,
P.A., 1212 SE Third Ave., Ft. Lauderdale, FL 33316 within TEN DAYS of the date of service
of this subpoena”, and to have with you the following documents and materials:
1. Full, unedited and complete copies of any and all photographs, video recordings,
and/or broadcast tapes related to the crash of a Tesla Motor vehicle (operated by Barrett
Riley) on Seabreeze Boulevard in Fort Lauderdale, FL on May 8, 2018, aired and/or
reported on May 8, 2018 and thereafter.
2. Full, unedited and complete copies of any and all photographs, video recordings,
and/or broadcast tapes depicting the scene of the crash of a Tesla Motor vehicle (operated
by Barrett Riley) on Seabreeze Boulevard in Fort Lauderdale, FL on May 8, 2018, aired
and/or reported on May 8, 2018 and thereafter.
3. Full, unedited and complete copies of any and all photographs, video recordings,
and/or broadcast tapes depicting the damages to the Tesla Motor vehicle (operated by
Barrett Riley) which crashed on Seabreeze Boulevard in Fort Lauderdale, FL on May 8,
2018, aired and/or reported on May 8, 2018 and thereafter.Page 7 4. Full, unedited and complete copies of any and all photographs, video recordings,
and/or broadcast tapes depicting the occupants of a Tesla Motor vehicle (operated by
Barrett Riley) which crashed on Seabreeze Boulevard in Fort Lauderdale, FL on May 8,
2018, aired and/or reported on May 8, 2018 and thereafter.
YOUR RESPONSE IS DUE BY:
10 DAYS FROM THE DATE OF SERVICE OF THIS SUBPOENA
*You may mail or deliver copies to the attorney whose name appears on this
subpoena and thereby eliminate your appearance at the time and place
specified above.
These items will be inspected and may be copies at that time. You will not be required to
surrender the original items. You may comply with this subpoena by providing legible copies of
the items to be produced to the attorney whose name appears on this subpoena on or before the
scheduled date of production. You may condition preparation of the copies upon the payment in
advance of the reasonable cost of preparation. You have the right to object to the production
pursuant to this subpoena at any time before the production by giving written notice to the attorney
whose name appears on this subpoena.
THIS WILL NOT BE A DEPOSITION, NO TESTIMONY WILL BE TAKEN.
If you fail to: (1) Appear as specified, or
(2) furnish the records instead of appearing as provided above, or
(3) object to this subpoena;
You may be in contempt of court. You are subpoenaed by the attorney whose name
appears on this subpoena and unless excused from this subpoena by the attorney or the Court,
you shall respond to this subpoena as directed.
DATED this day of June, 2019.
SCHLESINGER LAW OFFICES, P.A.
Attorneys for Plaintiffs
1212 SE Third Avenue
Fort Lauderdale, Florida
/s/ Zane Ber
Scott P. Schlesinger, Esq.
Florida Bar No.: scott@schlesingerlaw.com
Jonathan R. Gdanski, Esq.
Florida Bar No.: jonathan@schlesingerlaw.com
Zane Berg, Esq.
Florida Bar No.: zane@schlesingerlaw.com
PDF Page 1
PlainSite Cover Page
PDF Page 2
Filing # 90602002 E-Filed 06/05/2019 11:15:17 AM
IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
CASE NO.: CACE-19-000422
EDGAR MONSERRATT, as_ Personal
Representative of THE ESTATE OF
EDGAR MONSERRATT MARTINEZ,
Deceased,
Plaintiff,
V.
TESLA, INC. a/k/a TESLA FLORIDA,
INC., HALSTON LOYD, JAMES BB.
RILEY, individually, JAMES B. RILEY as
the Personal Representative of THE
ESTATE OF BARRETT RILEY, Deceased,
and JR CORPORATE SERVICES GROUP
LLC, a Florida limited liability company,
Defendants.
/
NOTICE OF PRODUCTION FROM NON-PARTY
YOU ARE HEREBY NOTIFIED that after ten (10) days from the date of service of this
Notice the undersigned will apply to the Clerk of this Court for the issuance of the attached
subpoenas directed to those listed below, who are not parties, to produce the items listed at the
time and place specified in their subpoenas:
1. NBC 6 South Florida
15000 SW 27' Street
Miramar FL 33027
2. CBS 4 Miami
8900 SW 18" Terrace
Doral FL 33172
[INTENTIONALLY LEFT BLANK]
** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/05/2019 11:15:17 AM.**#*
PDF Page 3
WE HEREBY CERTIFY that a true and correct copy of the foregoing has been served
via electronic mail and facsimile this 5“ day of June, 2019, to all parties on the attached list.
SCHLESINGER LAW OFFICES, P.A.
Attorneys for Plaintiffs
1212 SE Third Avenue
Fort Lauderdale, Florida 33316
/s/ Zane Ber
Scott P. Schlesinger, Esq.
Florida Bar No.: 444952
scott@schlesingerlaw.com
Jonathan R. Gdanski, Esq.
Florida Bar No.: 0032097
jonathan@schlesingerlaw.com
Zane Berg, Esq.
Florida Bar No.: 91317
zane(@schlesingerlaw.com
PDF Page 4
SERVICE LIST
SCOTT P. SCHLESINGER, ESQ. PHILIP HARNETT CORBOY, JR., ESQ.
JONATHAN R. GDANSKI, ESQ. CORBOY & DEMETRIO, P.C.
ZANE BERG, ESQ. 33 N. Dearborn Street
SCHLESINGER LAW OFFICES, P.A. Chicago IL 60602
1212 Southeast Third Ave Tel: (312)346-3191
Fort Lauderdale FL 33316 fhe@corboydemetrio.com
Tel: (954)320-9507 Co-Counsel for Plaintiff
Fax: (954)320-9509
scott@schelsingerlaw.com
jonathan@schlesingerlaw.com
zane@schelsingerlaw.com
priscilla@schlesingerlaw.com
Attorneys for Plaintiff, Edgar Monserratt, as Personal Representative of The Estate
of Edgar Monserratt Martinez, Deceased
ROBERT J. RUDOCK, ESQ.
WHITNEY V. CRUZ, ESQ.
BOWMAN AND BROOKE LLP
Two Alhambra Plaza, Suite 800
Coral Gables, FL 33134
Tel: (305) 995-5600
Fax: (305) 995-6090
Robert.Rudock@bowmanandbrooke.com
Whitney.Cruz@bowmanandbrooke.com
Attorneys for Defendant, Tesla, Inc. d/b/a Tesla Florida, Inc. and Halston Loyd
LAURIE A. PRIMUS, ESQ.
SELLARS, MARION & BACHI, P.A.
811 North Olive Avenue
West Palm Beach, FL 33401
Telephone: (561) 655-8111
Facsimile: (561) 655-4994
Service email: pleadings@smb-law.com
Attorneys for Defendants, James B. Riley and JR Corporate Services Group, LLC
PDF Page 5
IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
CASE NO.: CACE-19-000422
EDGAR MONSERRATT, as_ Personal
Representative of THE ESTATE OF
EDGAR MONSERRATT MARTINEZ,
Deceased,
Plaintiff,
V.
TESLA, INC. a/k/a TESLA FLORIDA,
INC., HALSTON LOYD, JAMES BB.
RILEY, individually, JAMES B. RILEY as
the Personal Representative of THE
ESTATE OF BARRETT RILEY, Deceased,
and JR CORPORATE SERVICES GROUP
LLC, a Florida limited liability company,
Defendants.
/
SUBPOENA DUCES TECUM (MAIL IN ONLY)
TO: NBC 6 South Florida
15000 SW 27 Street
Miramar FL 33027
YOU ARE COMMANDED TO appear at the law offices of Schlesinger Law Offices,
P.A., 1212 SE Third Ave., Ft. Lauderdale, FL 33316 within TEN DAYS of the date of service
of this subpoena*, and to have with you the following documents and materials:
1. Full, unedited and complete copies of any and all photographs, video recordings,
and/or broadcast tapes related to the crash of a Tesla Motor vehicle (operated by Barrett
Riley) on Seabreeze Boulevard in Fort Lauderdale, FL on May 8, 2018, aired and/or
reported on May 8, 2018 and thereafter.
2. Full, unedited and complete copies of any and all photographs, video recordings,
and/or broadcast tapes depicting the scene of the crash of a Tesla Motor vehicle (operated
by Barrett Riley) on Seabreeze Boulevard in Fort Lauderdale, FL on May 8, 2018, aired
and/or reported on May 8, 2018 and thereafter.
3. Full, unedited and complete copies of any and all photographs, video recordings,
and/or broadcast tapes depicting the damages to the Tesla Motor vehicle (operated by
Barrett Riley) which crashed on Seabreeze Boulevard in Fort Lauderdale, FL on May 8,
2018, aired and/or reported on May 8, 2018 and thereafter.
PDF Page 6
4. Full, unedited and complete copies of any and all photographs, video recordings,
and/or broadcast tapes depicting the occupants of a Tesla Motor vehicle (operated by
Barrett Riley) which crashed on Seabreeze Boulevard in Fort Lauderdale, FL on May 8,
2018, aired and/or reported on May 8, 2018 and thereafter.
YOUR RESPONSE IS DUE BY:
10 DAYS FROM THE DATE OF SERVICE OF THIS SUBPOENA
*You may mail or deliver copies to the attorney whose name appears on this
subpoena and thereby eliminate your appearance at the time and place
specified above.
These items will be inspected and may be copies at that time. You will not be required to
surrender the original items. You may comply with this subpoena by providing legible copies of
the items to be produced to the attorney whose name appears on this subpoena on or before the
scheduled date of production. You may condition preparation of the copies upon the payment in
advance of the reasonable cost of preparation. You have the right to object to the production
pursuant to this subpoena at any time before the production by giving written notice to the attorney
whose name appears on this subpoena.
THIS WILL NOT BE A DEPOSITION, NO TESTIMONY WILL BE TAKEN.
If you fail to: (1) Appear as specified, or
(2) furnish the records instead of appearing as provided above, or
(3) object to this subpoena;
You may be in contempt of court. You are subpoenaed by the attorney whose name
appears on this subpoena and unless excused from this subpoena by the attorney or the Court,
you shall respond to this subpoena as directed.
DATED this day June, 2019.
SCHLESINGER LAW OFFICES, P.A.
Attorneys for Plaintiffs
1212 SE Third Avenue
Fort Lauderdale, Florida 33316
/s/ Zane Ber
Scott P. Schlesinger, Esq.
Florida Bar No.: 444952
scott@schlesingerlaw.com
Jonathan R. Gdanski, Esq.
Florida Bar No.: 0032097
jonathan@schlesingerlaw.com
Zane Berg, Esq.
Florida Bar No.: 91317
zane@schlesingerlaw.com
PDF Page 7
IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
CASE NO.: CACE-19-000422
EDGAR MONSERRATT, as_ Personal
Representative of THE ESTATE OF
EDGAR MONSERRATT MARTINEZ,
Deceased,
V.
Plaintiff,
TESLA, INC. a/k/a TESLA FLORIDA,
INC., HALSTON LOYD, JAMES BB.
RILEY, individually, JAMES B. RILEY as
the
Personal Representative of THE
ESTATE OF BARRETT RILEY, Deceased,
and JR CORPORATE SERVICES GROUP
LLC, a Florida limited liability company,
Defendants.
/
SUBPOENA DUCES TECUM (MAIL IN ONLY)
TO: CBS 4 Miami
8900 SW 18 Terrace
Doral FL 33172
YOU ARE COMMANDED TO appear at the law offices of Schlesinger Law Offices,
P.A., 1212 SE Third Ave., Ft. Lauderdale, FL 33316 within TEN DAYS of the date of service
of this subpoena”, and to have with you the following documents and materials:
1. Full, unedited and complete copies of any and all photographs, video recordings,
and/or broadcast tapes related to the crash of a Tesla Motor vehicle (operated by Barrett
Riley) on Seabreeze Boulevard in Fort Lauderdale, FL on May 8, 2018, aired and/or
reported on May 8, 2018 and thereafter.
2. Full, unedited and complete copies of any and all photographs, video recordings,
and/or broadcast tapes depicting the scene of the crash of a Tesla Motor vehicle (operated
by Barrett Riley) on Seabreeze Boulevard in Fort Lauderdale, FL on May 8, 2018, aired
and/or reported on May 8, 2018 and thereafter.
3. Full, unedited and complete copies of any and all photographs, video recordings,
and/or broadcast tapes depicting the damages to the Tesla Motor vehicle (operated by
Barrett Riley) which crashed on Seabreeze Boulevard in Fort Lauderdale, FL on May 8,
2018, aired and/or reported on May 8, 2018 and thereafter.
PDF Page 8
4. Full, unedited and complete copies of any and all photographs, video recordings,
and/or broadcast tapes depicting the occupants of a Tesla Motor vehicle (operated by
Barrett Riley) which crashed on Seabreeze Boulevard in Fort Lauderdale, FL on May 8,
2018, aired and/or reported on May 8, 2018 and thereafter.
YOUR RESPONSE IS DUE BY:
10 DAYS FROM THE DATE OF SERVICE OF THIS SUBPOENA
*You may mail or deliver copies to the attorney whose name appears on this
subpoena and thereby eliminate your appearance at the time and place
specified above.
These items will be inspected and may be copies at that time. You will not be required to
surrender the original items. You may comply with this subpoena by providing legible copies of
the items to be produced to the attorney whose name appears on this subpoena on or before the
scheduled date of production. You may condition preparation of the copies upon the payment in
advance of the reasonable cost of preparation. You have the right to object to the production
pursuant to this subpoena at any time before the production by giving written notice to the attorney
whose name appears on this subpoena.
THIS WILL NOT BE A DEPOSITION, NO TESTIMONY WILL BE TAKEN.
If you fail to: (1) Appear as specified, or
(2) furnish the records instead of appearing as provided above, or
(3) object to this subpoena;
You may be in contempt of court. You are subpoenaed by the attorney whose name
appears on this subpoena and unless excused from this subpoena by the attorney or the Court,
you shall respond to this subpoena as directed.
DATED this day of June, 2019.
SCHLESINGER LAW OFFICES, P.A.
Attorneys for Plaintiffs
1212 SE Third Avenue
Fort Lauderdale, Florida 33316
/s/ Zane Ber
Scott P. Schlesinger, Esq.
Florida Bar No.: 444952
scott@schlesingerlaw.com
Jonathan R. Gdanski, Esq.
Florida Bar No.: 0032097
jonathan@schlesingerlaw.com
Zane Berg, Esq.
Florida Bar No.: 91317
zane@schlesingerlaw.com